When Form Follows Dysfunction

by M. Sigmund ShapiroMay 1, 2002

The most essential Customs form in the clearance of imported merchandise is CF 3461 captioned ENTRY/IMMEDIATE DELIVERY. The current model was developed by Customs in 1989 and is used to enable the importer/broker to detail information so Customs can determine whether or not to examine the shipment. It is a paper backup to an electronic transmission of the data. The form is a five-part set; page one is pink, followed by three white copies, and a yellow copy on the back. All copies are carbonized. It is submitted at time of entry if required by Customs but a large percentage are simply held by the broker and are never seen by Customs.

Most brokers purchase the forms for use in dot matrix printers, but a few enterprising souls have been able, in certain ports, to laser print the forms all in one color (white). The advantages are obvious: elimination of inefficient and archaic dot matrix printers, and the cost of expensive custom designed forms. Other ports, however refuse to allow laser printing, claiming that a Customs directive 2110-036 in 2000, requires adherence to, among other things, color. (The fact that such a directive came out just two years ago is astonishing in itself.) In an effort to eliminate the problem we contacted Customs headquarters and were told that acceptance of laser printed 3461’s was the decision of each individual port, but that the matter would be analyzed with a view to enhancing an extremely important national goal of uniformity of operation in the data processing arena. We were told however that the regulations would have to be changed. We suggested that the matter could be implemented immediately by calling it a “test program” such as those along the Canadian border that have been in effect since the late ‘40s without ever having been blessed by regulatory authority. We’ll see.

In the meantime, we have written to various ports for permission. A few have given an OK after requesting a sample of the laser form. Others turned us down flat. But one port reflected the inability to adapt to the electronic age. We were told that the five-part laser printed set was OK as long as it was submitted with carbon paper interleaves!

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